Release, Discharge, Withdrawal and Subordination of Tax Liens

A federal tax lien on real or personal property may be terminated or altered in the following ways:
(1) The IRS must release a tax lien if the IRS determines that the tax liability has been paid or is legally unenforceable.
(2) The IRS has discretion to discharge specific property from a tax lien in certain circumstances.
(3) The IRS may withdraw a notice of federal tax lien even though the lien has not been paid or satisfied, in certain circumstances.
(4) The IRS may subordinate tax liens in certain circumstances.
(5) The IRS may issue a certificate of non-attachment stating that a lien does not attach to a person’s property (other than the person against whom the tax was assessed), if that person is or may be injured by a notice of lien.
A taxpayer or third party whose property is subject to a federal tax lien may appeal denials of requests for these actions through the Collection Appeals Program (CAP). The taxpayer first contacts the IRS and discusses the case with a Collections manager. If the issue remains unresolved, the taxpayer can request Appeals consideration by filing Form 9423, Collection Appeal Request. Instructions for Form 9423.